Friday, January 14, 2011

ACRS Weighs In on Safety Culture Policy

In mid-December the Advisory Committee on Reactor Safeguards (ACRS) provided the results of its review of the NRC’s proposed nuclear safety culture policy in a letter to NRC Chairman Jaczko.*  The letter reiterated the approach and general structure of the proposed policy and reached a favorable conclusion.  Perhaps the most interesting comment in the main body of the letter is the following:

“Well-intentioned attempts at improving safety and effectiveness have faltered through efforts to overly prescribe correct behavior and to apply rigid scoring systems. We urge that the staff encourage approaches that emphasize thinking and safety awareness over scorecards of metrics that can induce complacency and rote compliance. Issuance of a policy statement, rather than a regulation, is likely to be a more effective way to appropriately engage all the stakeholders.” (p. 4)

The statement is a bit cryptic and we can only guess what the ACRS has in mind when it refers to “scorecards of metrics” or “overly prescribing behavior”.  Are they referring to the ROP?  Is the ACRS concerned that reliance on the ROP metrics (and their almost uniformly green status) may be lulling the industry and the NRC into complacency?  Equally uncertain is why the ACRS believes that a policy statement will lead to more effective results. 

Apparently we are not the only ones to suffer uncertainty.  The ACRS letter includes “Additional Comments” (read: dissenting comments) by three members** who state:

“It is not entirely clear to us what is meant by implementing a policy statement that lacks the authority of regulation. It appears that implementation of the safety culture policy statement may be an indirect method of imposing requirements on licensees without the discipline of the regulatory process. This, of course, is not acceptable.” (p. 4)

Part of the confusion may lie in the intent and authority associated with NRC policy statements.  It appears that the dissenting members feel that a policy statement would be a back door method to impose “requirements”.  Is that true?  We will follow with a detailed look at policy statements and their effect.

*  Letter dated Dec 15, 2010 from S. Abdel-Khalik (ACRS) to G. Jaczko (NRC), subject "Safety Culture Policy Statement," ADAMS Accession Number ML103410358.

** D.A. Powers, J.S. Armijo and J.L. Rempe.

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